R (Prudential Plc) v Special Commissioner of Income Tax

JurisdictionEngland & Wales
JudgeLord Justice Aikens,Lord Justice Lloyd,Lord Justice Stanley Burnton,Lord Justice Mummery
Judgment Date14 December 2010
Neutral Citation[2010] EWCA Civ 1094,[2010] EWCA Civ 355
Docket NumberCase No: B2/2009/1240,Case No: C1 2009/2544
CourtCourt of Appeal (Civil Division)
Date14 December 2010
    • This document is available in original version only for vLex customers

      View this document and try vLex for 7 days
    • TRY VLEX

Unlock full access with a free 7-day trial

Transform your legal research with vLex

  • Complete access to the largest collection of common law case law on one platform

  • Generate AI case summaries that instantly highlight key legal issues

  • Advanced search capabilities with precise filtering and sorting options

  • Comprehensive legal content with documents across 100+ jurisdictions

  • Trusted by 2 million professionals including top global firms

  • Access AI-Powered Research with Vincent AI: Natural language queries with verified citations

vLex

Unlock full access with a free 7-day trial

Transform your legal research with vLex

  • Complete access to the largest collection of common law case law on one platform

  • Generate AI case summaries that instantly highlight key legal issues

  • Advanced search capabilities with precise filtering and sorting options

  • Comprehensive legal content with documents across 100+ jurisdictions

  • Trusted by 2 million professionals including top global firms

  • Access AI-Powered Research with Vincent AI: Natural language queries with verified citations

vLex

Unlock full access with a free 7-day trial

Transform your legal research with vLex

  • Complete access to the largest collection of common law case law on one platform

  • Generate AI case summaries that instantly highlight key legal issues

  • Advanced search capabilities with precise filtering and sorting options

  • Comprehensive legal content with documents across 100+ jurisdictions

  • Trusted by 2 million professionals including top global firms

  • Access AI-Powered Research with Vincent AI: Natural language queries with verified citations

vLex

Unlock full access with a free 7-day trial

Transform your legal research with vLex

  • Complete access to the largest collection of common law case law on one platform

  • Generate AI case summaries that instantly highlight key legal issues

  • Advanced search capabilities with precise filtering and sorting options

  • Comprehensive legal content with documents across 100+ jurisdictions

  • Trusted by 2 million professionals including top global firms

  • Access AI-Powered Research with Vincent AI: Natural language queries with verified citations

vLex

Unlock full access with a free 7-day trial

Transform your legal research with vLex

  • Complete access to the largest collection of common law case law on one platform

  • Generate AI case summaries that instantly highlight key legal issues

  • Advanced search capabilities with precise filtering and sorting options

  • Comprehensive legal content with documents across 100+ jurisdictions

  • Trusted by 2 million professionals including top global firms

  • Access AI-Powered Research with Vincent AI: Natural language queries with verified citations

vLex

Unlock full access with a free 7-day trial

Transform your legal research with vLex

  • Complete access to the largest collection of common law case law on one platform

  • Generate AI case summaries that instantly highlight key legal issues

  • Advanced search capabilities with precise filtering and sorting options

  • Comprehensive legal content with documents across 100+ jurisdictions

  • Trusted by 2 million professionals including top global firms

  • Access AI-Powered Research with Vincent AI: Natural language queries with verified citations

vLex
6 cases
  • Stewart Ford v Financial Services Authority—and Peter Johnson and Mark Owen and Another
    • United Kingdom
    • Queen's Bench Division (Administrative Court)
    • 18 April 2012
    ...word on the topic of privilege in advice coming from organisations like Grant Thornton must await the decision of the Supreme Court in the Prudential case. 19 Mr Malek is, of course, correct in his submission that on the strength of my conclusions the FSA relied to an extent on the LPP Mate......
  • G v G
    • United Kingdom
    • Family Division
    • 24 April 2015
  • R (Prudential Plc) v Special Commissioner of Income Tax
    • United Kingdom
    • Supreme Court
    • 23 January 2013
    ...Lord Taylor of Gosforth CJ in R v Derby Magistrates'; Court, Ex p B [1996] AC 487, 504–505. As Lloyd LJ said in the Court of Appeal at [2011] QB 669, 709, para 30, LAP and its rationale was probably first coherently characterised in a judgment by Lord Brougham LC in Greenough v Gaskell (1......
  • R Stewart Ford v The Financial Services Authority Peter Johnson and Mark Owen (Interested Parties)
    • United Kingdom
    • Queen's Bench Division (Administrative Court)
    • 11 October 2011
    ...19 Beav 401) to communications with a member of a relevant legal profession': See R (Prudential) v. Income Tax Special Commissioner [2011] 2 WLR 50 at para [72] and [82] to [85] per Lloyd LJ. See also the discussion of Wheeler v le Marchant (1881) 17 Ch D 675 in the judgment of the Court of......
  • Request a trial to view additional results
6 firm's commentaries
  • Privilege update - two new decisions from the UK
    • New Zealand
    • Mondaq New Zealand
    • 1 November 2010
    ...such as a settlement agreement, and R (on the application of Prudential PLC and Anor) v Special Commissioner of Income Tax and Ors [2010] EWCA Civ 1094 (13 October 2010) in which the English Court of Appeal declined to extend legal professional privilege to chartered accountants giving lega......
  • UK Supreme Court Declines To Extend Scope Of Legal Advice Privilege
    • United Kingdom
    • Mondaq United Kingdom
    • 29 January 2013
    ...issue. Footnotes 1 R (on the application of Prudential PLC & Anor) v Special Commissioner of Income Tax & Anor [2013] UKSC 1 2 [2010] EWCA Civ 1094 Visit us at Mayer Brown is a global legal services provider comprising legal practices that are separate entities (the "Mayer Brown Pra......
  • Court Of Appeal Rejects Appeal For Extension Of Legal Privilege To Accountants
    • United Kingdom
    • Mondaq United Kingdom
    • 21 October 2010
    ...hearing of issues which raise matters of public policy. Footnotes 1 Prudential Plc v Special Commissioners of Income Tax and another [2010] EWCA Civ 1094 2 Paragraph 73 [2009] EWHC 2494 The content of this article is intended to provide a general guide to the subject matter. Specialist advi......
  • Court of Appeal Refuses to Extend LPP to Accountants
    • United Kingdom
    • Mondaq United Kingdom
    • 12 November 2010
    ...2 Prudential PLC and Prudential (Gibraltar) Limited v Special Commissioner of Income Tax and Philip Pandolfo (HM Inspector of Taxes) [2010] EWCA Civ 1094 The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your s......
  • Request a trial to view additional results
3 books & journal articles
  • Indexes
    • United Kingdom
    • Sage International Journal of Evidence & Proof, The No. 18-4, October 2014
    • 1 October 2014
    .... . . . . . . . . . . . . . . . . . . . . . . . . . . . . .66R (on the application of Prudential plc) v SpecialCommissioner of Income Tax [2011] QB 669,[2009]EWHC 2494 (Admin). . . . . . . . . . . . . . 66R (on the application of Prudential plc) v SpecialCommissioner of Income Tax [2013] UK......
  • An Unsatisfactory Stalemate: R (on the Application of Prudential plc) v Special Commissioner of Income Tax
    • United Kingdom
    • Sage International Journal of Evidence & Proof, The No. 18-1, January 2014
    • 1 January 2014
    ...replaced by the Finance Act 2008, s. 113 andSched. 36. 3 R (on the application of Prudential plc) v Special Commissioner of Income Tax [2011] QB 669, [2009] EWHC2494 (Admin) at [8] and [2010] EWCA Civ 1094 at [2]. 4 [2013] UKSC 1, [2013] 2 WLR 325 at [122]. 5 Ibid. at [137]. 6 Ibid. at [148......
  • Case Commentaries
    • United Kingdom
    • Sage International Journal of Evidence & Proof, The No. 15-1, January 2011
    • 1 January 2011
    ...privilege for accountants—United KingdomThe applicant in R (on the application of Prudential Plc) vSpecial Commissioner of IncomeTax [2010] EWCA Civ 1094 applied for a judicial review to quash notices issuedunder the Taxes Management Act 1970, s. 20 (now Finance Act 2008, Sched. 36) toprodu......

VLEX uses login cookies to provide you with a better browsing experience. If you click on 'Accept' or continue browsing this site we consider that you accept our cookie policy. ACCEPT